Picked up from Prestonblog, CABE (Commission for Architecture and the Built Environment), a letter of concern to the developers of the Tithebarn scheme for Preston city centre on the PrestonLancs forum, . In the letter they raise concerns that the new development does not seem to have had enough thought put into sustainabilty and other key aspects.

(comments of interest underlined)

Sustainability strategies

A scheme of this size and the mix of uses proposed suggest that it should set high standards in terms of energy efficiency and environmental design. We are therefore disappointed by the minimal targets set in this planning application. On page three of the statement under the ‘Energy’ heading, reference is made to the use of renewable energy sources to provide a proportion of the energy requirements of the private dwellings. However, the only targets relating to carbon reduction are the statutory minimum allowed by the building regulations. We are concerned that this might lead to the relaxing of energy standards of the dwellings and use of an unspecified level of on-site renewable energy to improve this up to the minimum allowed by the regulations. Therefore, we would question whether the proposals satisfy the council’s Interim Planning Statement No.3 (IPS3) which requires a 10% saving in carbon over and above total energy use.

We are also concerned that the central energy centre serving a community energy system has been excluded from the current planning application and that this might result in control over the energy systems adopted in most of the buildings being handed over to future developers. In our view, the commitment to a central energy centre should be established in this planning application and conditioned appropriately. Comprehensive redevelopment of the site creates an opportunity to put in place such infrastructure, which is far more difficult to retrofit. The document also suggests that not all buildings would connect a common energy system to achieve the benefits and synergies between different uses of CHP to reduce carbon, which would be a missed opportunity.

The sustainability statement does not seem to acknowledge the existence of the PPS1 Supplement on Climate Change and the need to consider systems at the community scale. Furthermore, given the likely extended build-out phasing (likely to extend beyond 2016) there appears to be no strategy for dealing with zero carbon homes or the scale of carbon reductions likely to be needed of the non-domestic stock given that Government intend to achieve zero carbon by 2019.

The reference to being on target to meeting the UK’s pledge to cut carbon emissions by 60% by 2050 does not acknowledge the recent revised target of 80% and is, in our view, misleading because it does not consider all the energy use of the buildings or acknowledge that the proposals are adding to the UK buildings stock and hence energy demand.

(this is an important issue – the difference between 60 and 80% would have a very significant impact on design and energy considerations)

We would ask the design team to address the concerns raised above at this point to give the local authority the assurance that Preston Tithebarn will be meeting the standards on sustainability expected of a development of this significance.

On a related sustainability theme, that of transport, CABE also has concerns

While we acknowledge the masterplan brief required that Preston’s existing bus station be replaced, we are disappointed that an alternative way to bring buses into Preston could not have been found. Examples in other cities have shown that a simple on-street drop-off point can be more successful and effective than an expensive bus station building. Furthermore, the large footprint of a conventional bus station with many parked buses and attendant noise and exhaust fumes can have a negative impact on adjacent areas; we would expect that the necessary measures have been undertaken to minimise these nuisances. The overall strategy for the bus routes also needs careful consideration in terms of bus movements and congestion to prevent detrimental effects on the streets used by buses.

Ouch. Back to the sustainable drawing board …

It will be interesting to see how Preston now deal with the planning application and whether CABE’s comments are taken on board, or a development tagged as unsustainable is allowed to proceed.

I have searched for but cannot find the application online – if I do I will review and comment – and links would be useful.